Status of Elephant Import Suspensions for Zimbabwe and Tanzania

Written By John J. Jackson III, Conservation Force Chairman & President

(posted August 2014)

As this went to print, decisions by US Fish & Wildlife Service (USFWS) on the elephant import suspensions for both Zimbabwe and Tanzania were imminent. First, Zimbabwe. USFWS was expected to make a “final” determination on the interim suspension by mid-July and confirmed to us that it was in fact reviewing the responses provided by Zimbabwe and the extensive comment (100-plus documents) filed by Conservation Force. Zimbabwe also confirmed to USFWS that they have accepted an offer from Conservation Force and Shikar Safari Club to fund an up-to-date National Elephant Action Plan. That important impediment to lifting the suspension has been removed.

Zimbabwe has also confirmed that all elephant areas are being surveyed over the next few months as part of the Pan-Africa Survey of all of Africa. Some are already being surveyed. There was a dispute over the methodology of the surveys, but that too has been resolved so the results will be compiled by a comparable, agreeable technique. Gonarezhou National Park may not be included because it has so recently been surveyed, 2013, which survey estimate is increasing, even though it may be said to be one of the most vulnerable areas of Zimbabwe bordering Mozambique.

The alleged “siege,” as USFWS described it, in Hwange National Park has been dispelled. That has been shown to be the poisoning of 100, not 300 elephant. The poisoning was discovered and reported by none other than the adjacent hunting operator, and the poachers were caught and are serving stiff sentences. It was stale news more than a year ago. Over a dozen were arrested and sentenced up to 16 years imprisonment. That is serious enforcement, not neglect as USFWS represented. It was no longer an issue when the suspension was announced a year afterwards. At the 65th Standing Committee meeting of CITES in Geneva on July 10, the Director General of Zimbabwe denounced the false reports about the nominal incident to the whole world once again.

One other important mistake made by USFWS was a serious misinterpretation of the IUCN African Elephant Specialist Group’s African Elephant Database (AED). The USFWS misinterpreted the population estimate data on Zimbabwe to mean its elephant population was down by nearly half when it is stable or increasing. We discovered this early and informed the USFWS of its mistake, but as recently as late June USFWS was still misrepresenting this. In an Oversight Hearing before the Committee on Natural Resources (June 24, 2014), one of Zimbabwe’s senior research ecologists testified at least five times that the Zimbabwe elephant population was stable or increasing, while the USFWS representative contradictorily misrepresented that the population had been halved. What happened was the AED reflected a change in the quality of the estimate in the Hwange National Park area merely because of the passage of time between aerial surveys. This did not change the total number of estimated elephant; it merely moved the estimate to a different column of lower quality or reliability and did that as a matter of procedure when a survey is aged, not because it had become suspect. There were actually non-aerial surveys demonstrating an increasing population that were not included in the AED, so an increase was the most up-to-date information. The Chair of the African Elephant Specialist Group has now written and also discussed the USFWS error with them. It was a major flaw in USFWS’ negative assumptions about Zimbabwe.

In consideration of these points and so much more, I do expect USFWS to make a positive enhancement finding shortly, but, of course, I am sticking my neck out. The questionnaire USFWS sent to Zimbabwe should define the issue, but we have to wait and see. USFWS may choose to send a follow-up questionnaire before lifting the suspension, which will extend into the season. Tanzania presents a different picture because the Tanzania elephant remains on Appendix I of CITES and because of the admitted poaching and drastic decline of elephant. On the other hand, Tanzania is sparing no effort to contend with the unforeseeable illegal ivory demand driving poaching and trafficking. Who could foresee such an unprecedented demand? Again, as this went to press a decision on the administrative appeals of the permits that have been denied had been imminent, but we received too many signals that the decision was going to be negative. Conservation Force asked for an extension of time to file an expert report on a pivotal management issue and additional quantification of the benefits arising from the hunting operators in the elephant areas. Conservation Force has been granted an extension of time to submit an expert report being prepared by elephant expert Rowan Martin on the key issue of the sustainability of authorizing imports when the population has been and may still be in decline. This will delay the administrative appeal determination 45 days, but there is little doubt that the issue is pivotal. “Is it sustainable to use/hunt a population that is in decline?” The hard documents demonstrate that the operators contribute millions of dollars a year to conservation, anti-poaching and community programs that enhance the survival of the species in addition to the operating budget of the wildlife authority.

This core issue with imports from Tanzania arises from the accepted fact that the population is in decline, it is not stable or increasing. The USFWS questions whether or not it is sustainable to hunt a population that is declining. In fact, it may not still be in decline and may not have declined as much as thought. All indicators are that the rate of poaching has already been reduced and Tanzania and the hunting operators have taken drastic measures to control the poaching. One hunting operator, already spending up to half a million dollars a year on anti-poaching, has just donated two new vehicles and doubled the number of game scouts in his area, for just one example.

Whether or not a game population has to be stable or growing to be hunted and trophies to be importable goes back to the Elephant Guidelines fight in 1991-92. At that time, the USFWS promised to be more flexible. The number of elephant taken in Tanzania is inconsequential, i.e. less than a small fraction of one percent. This is wholly offset by the number of elephant saved by the hunting, so it is a net gain, not an additive loss. If the population is declining, it is declining far less because of the elephants being saved by the hunting activity. The hunting is the very medicine necessary to cure the ill – control and disincentivize the poaching.

We have not given up on reopening Tanzania this year, 2014, but it is a harder sell than Zimbabwe. Tanzania admits the poaching crises and is asking the world for help. No one could have foreseen the level of demand and unprecedented poaching Tanzania has experienced. All Tanzania populations are also being surveyed this year (2014) as part of the Pan-African survey and that surveying has already begun.

Tanzania has complied with the suggestion by USFWS in its correspondence that Tanzania reduce its quota. It has halved its quota effective July 2014. We await the USFWS decision on the pending permit appeals and some new import permit applications Conservation Force has filed while we continue on every front. If the pending appeals are denied, we have continued building a great deal of additional information to submit with the final appeal and oral argument before the USFWS Director. Hunting is a large part of the conservation solution, while the quota is not statistically significant.

Some are critical of Tanzania for losing so many elephant, but in reality Tanzania is a pace-setter. It still has one of the largest elephant populations, the most habitat, the most lion, the most buffalo and so much more. Don’t blame Tanzania for the unforeseeable.